A Gap Analysis of Ship-Recycling Practices in Indonesia

Round 1

Reviewer 1 Report

This study investigates the disparity between the current ship recycling practices in Indonesia and the requirements of related international and national regulations, the comments are as follows.

1. The abstract is too long, which needs to be improved.
2. Literature review part shall be included in the paper.
3. The structure of this study need to be re-constructed, it is not appropriate that the second part of the paper is the Results, the third part is Discussion, which is also inappropriate.
4. Tables can be used to compare the same and difference among the international regulations, which would be more readable to readers.
5. The gap analysis part needs to be elaborated.
6. There seems no clear linkage between the international regulations and the national regulations, which needs to elaborated, such as how the international regulations can be used /adapted to improve the national regulations in personnel health and safety, as well as the environment, and so on.
7. The implications and limitations of this study need to be included in Conclusion part.

Author Response

1. The abstract has been shortened and improved
2. The literature review has been included in the paper
3. The structure of the manuscript has been re-constructed
4. Tables are used for Lesson Learnt From Bench Marking, and for Summary of Gap Analysis
5. The gap analysis has been elaborated
6. The international and national regulations have been elaborated
7. The implication of the study has been included in the conclusion section

Reviewer 2 Report

Dear Authors,

Thank you for writing this manuscript on this important field. The discussion on Indonesian shipbreaking is a new addition to the shipbreaking research. This study is intended to conduct a policy gap analysis of the international policy regulations and the national policy regulations and then offer an analysis of the implementation gap in the in-ground practice.

This study is however missing some important aspects regarding the analysis of the international regulations.  Some of the aspects have been mentioned in the following. The analysis of the national regulations is surprisingly short and could be articulated by choosing themes and issues from the international and national regulations. In addition, the shipbreaking literature is not well reviewed concerning policy regime and perspective differences among the national and international policy stakeholders, even differences of opinion with national monitoring body to the yard owners and managers. The study may be improved by Rahman et al. 2018, Rahman and Mayer (2016) and Alam and Faruque (2014).

Alam, S., & Faruque, A. (2014). Legal regulation of the shipbreaking industry in Bangladesh: The international regulatory framework and domestic implementation challenges. Marine policy, 47, 46-56.

Rahman, S. M., Schelly, C., Mayer, A. L., & Norman, E. S. (2018). Uncovering discursive framings of the Bangladesh shipbreaking industry. Social Sciences, 7(1), 14.

Rahman, S. M., & Mayer, A. L. (2016). Policy compliance recommendations for international shipbreaking treaties for Bangladesh. Marine Policy, 73, 122-129.

Gregson, N., Crang, M., Ahamed, F., Akhter, N., & Ferdous, R. (2010). Following things of rubbish value: End-of-life ships,‘chock-chocky’furniture and the Bangladeshi middle class consumer. Geoforum, 41(6), 846-854.

Du, Z., Zhu, H., Zhou, Q., & Wong, Y. D. (2017). Challenges and solutions for ship recycling in China. Ocean Engineering, 137, 429-439.

I hope that these comments would be helpful.

 Detail comments:

In lines 53-54, some citation that demonstrates the domestic demand based recycling can be cited.

In line 88, a new paragraph started all of a sudden. It seems that there may have at least a short paragraph that indicates how the international policy environment and local policy differs and permit the substandard recycling practices. Some policy gap analysis studies have already been conducted and their lessons can improve the paper substantially.

As an added evaluation of the HKC convention, I think that HKC offers a tacit approval of the recycling of ships in the south Asian nations and is intended to improve the substandard practices through certification, inspection and enforcement in all stages of EoL ship transportation.

In the Basel Convention, major argument is whether hazardous waste ban includes the EoL ships themselves as they carry hazardous elements or whether only the hazardous material that they carry. As far as the Basel convention is concern, Basel convention can not prohibit EoL ships to be recycled as the ships themselves are not waste.

Regarding the EU- SRR, the major issue is that only a small number of EU owned ships are EU flagged and thus, a substantial number of EU ships remains outside the scope of the EU-SRR. The port registration covers how many more EoL ships under the regulations is not quite clear, I think.

The policy gap analysis misses the theoretical framework under which a gap analysis can be effectively conducted. Rahman and Mayer (2016), Alam and Faruque (2014) along with others have some policy related discussion that might help deepen the analysis in this paper.

Author Response

1. Benchmark to the world-leading ship recycling countries has been included as references on how the efforts have been done toward green and sustainable ship recycling industry
2. Review on international and national regulations has been elaborated
3. Information obtained from the field visit has been included
4. Domestic demand-based recycling is  explained in line 41 - 49
5. The summary of the gap analysis is presented in table 2.
6. All international and national regulations have been reviewed more critically
7. Arguments on results of the gap analysis are presented in the results and discussions section